Williams v. Correction Officer Priatno, No. 14-4777 (2d Cir. 2016)Annotate this Case
Plaintiff filed suit against Officer Priatno and Gammone under 42 U.S.C. 1983, alleging that the officers violated his Eighth Amendment rights when they brutally beat him for talking back to another officer when he was an inmate at Downstate Correctional Facility. At issue is whether plaintiff exhausted all available administrative remedies prior to filing suit in the district court, as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). The court concluded that the prison's grievance process was not available to plaintiff because the applicable grievance procedures are “so opaque” and confusing that they were, “practically speaking, incapable of use.” Because plaintiff satisfied the PLRA's exhaustion requirement, the court reversed and remanded.